Submission: Water Efficiency Labelling and Standards Scheme Independent Review

Water Efficiency Labelling and Standards scheme independent review
WELS Regulator
GPO Box 858
Canberra ACT 2601
Via email: wels@agriculture.gov.au 

Re: Water Efficiency Labelling and Standards scheme independent review

Thank you for the opportunity to respond to this WELS scheme review. VicWater is the peak body of the Victorian water industry with its membership comprising Victoria’s 19 statutory water corporations. Victorian water corporations are responsible for the provision of urban water and wastewater services, rural water supply including irrigation and related drainage services. This letter includes commentary on a selection of consultation questions relevant to VicWater and its members. 

• VicWater supports the objectives of the WELS scheme; improving water use efficiency continues to make an important contribution to delaying costly supply augmentation as urban water supplies come under increasing pressure from climate change and population growth. Victorian water corporations have promoted the uptake of WELS starred water-efficient appliances for many years, including providing the free exchange of low for high efficiency shower heads, and community education on the choice and use of water efficient appliances. Research at a Melbourne metropolitan water retailer indicates that 74% of respondents (n=2,780) are willing to install water-savings devices in their home, and almost half of all customers seek further guidance on saving water around their home. 
• VicWater supports the regular review and improvement of the WELS scheme to ensure it is keeping pace with customer values and technological advancement. With this in mind, VicWater questions the approach taken to the preparation of the discussion paper, which appears to overlook opportunities to tackle the full scope outlined in the review Terms of Reference. Almost 30 pages of the discussion paper (of 41 in total) is spent repeating a series of multiple-choice stakeholder questions. In particular, the discussion paper takes a narrow approach to considering issues that would fall under item 4 of the terms of reference “potential improvements to the operation of the scheme… to reduce water consumption” and continue to advance water saving objectives. For example, little consideration appears to be given to updating the actual standards to reflect current best practice.
• In relation to the above, VicWater supports a minimum standard for showerheads, washing machines, dishwashers, and toilets of 4-star, with the further introduction of a 5-star showerhead rating (to replace the 4F range of 4.5-6.0 litres per minute). VicWater notes that some jurisdictions in the United States have already successfully implemented a more stringent shower head standard than the WELS 4E standard. Research in Melbourne indicates that showers continue to be the largest component of total household water use (over 30%) and is thus an important target for further savings. Reducing hot water use naturally has a concomitant energy savings and carbon emission reduction that should be acknowledged. 
• VicWater also recommends greater alignment with other Australian standard schemes, such as energy efficiency labelling. There is an ongoing need for the WELS scheme to keep pace with customer preferences for accessing information. It must be as easy as possible for customers to access and compare water and energy use, including whilst shopping online. 

VicWater welcomes its further involvement in this review. Please contact James Cleaver should you have any questions, or if you would like to discuss any of the issues we have raised in greater detail. 

Yours sincerely 

Peter Morison
Chief Executive Officer